By Carlos Avalos
Secret Board Positions, Undisclosed Contracts, and Campaign Cash Raise Questions About Ethics Violations. An FPPC complaint alleges systemic conflicts of interest involving the county’s top education officials. San Bernardino County’s highest-ranking education officials are facing serious allegations of ethics violations, undisclosed conflicts of interest, and potential criminal conduct in a complaint filed with California’s Fair Political Practices Commission (FPPC) on September 3, 2025.
The complaint targets County Superintendent Ted Alejandre and Chief Business Officer Richard DeNava, alleging they maintained secret leadership positions at SchoolsFirst Federal Credit Union while simultaneously overseeing lucrative contracts with the same institution, creating what critics describe as a web of financial entanglements that violated multiple state laws.
At the center of the allegations is SchoolsFirst Federal Credit Union, which serves as the third-party administrator for San Bernardino County Superintendent of Schools’ (SBCSS) employee retirement plans, a contract worth tens of thousands of dollars annually that was never disclosed to the county board or public. While this contract generated substantial revenue for SchoolsFirst, both Alejandre and DeNava held undisclosed leadership positions within the credit union’s governance structure, creating what the complaint describes as an “unprecedented dual audit conflict.”
Ted Alejandre, who earns over $300,000 annually as county superintendent, allegedly served in two key SchoolsFirst positions: 2022, member of SchoolsFirst’s Supervisory Committee, and 2023: Chairman of the Supervisory Committee. The Supervisory Committee wields significant power within credit union governance, including hiring external auditors (Moss Adams LLP handled SchoolsFirst’s 2023 audit), reviewing internal audit reports, overseeing risk management, and monitoring regulatory examinations.
Here’s where the conflict becomes particularly troubling: As county superintendent, Alejandre also controls SBCSS’s audit process, including selecting auditors and setting audit scope, powers that the county board does not share.
“This means Alejandre simultaneously controlled SBCSS’s audits and SchoolsFirst’s audits,” the complaint states, “creating a dual audit conflict that allowed him to suppress or shape findings on both sides of the relationship without oversight or public transparency.”
Meanwhile, Alejandre’s financial disclosure forms show he received thousands of dollars annually from SchoolsFirst, including $6,746 plus $3,479 in 2021 alone, and $7,795 plus $6,567 plus $1,604 plus $693 in 2023.
Richard DeNava’s alleged violations span an even longer period. The complaint alleges he held various SchoolsFirst positions since 2014:2014-2020: Advisory Council, Finance Committee, and Associate Director roles, 2021-2024: Full Board of Directors member with fiduciary duties to act in SchoolsFirst’s best interests, and 2019: Vice President of the California Association of School Business Officials (CASBO).
Despite these significant positions, DeNava’s required financial disclosure forms (Form 700s) from 2018-2024, all declare “None” for outside positions and economic interests, a pattern the complaint describes as systematic concealment.
The complaint alleges violations of several California statutes designed to prevent exactly this type of conduct, such as the Political Reform Act Violations. California’s Political Reform Act (Government Code §§ 81000 et seq.) requires public officials to disclose financial interests that could create conflicts. The law mandates Form 700 filings that provide public transparency about officials’ economic relationships. Both officials allegedly failed to disclose their SchoolsFirst governance roles on these required forms, violations that can result in fines up to $5,000 per violation plus three times the amount of any unlawful benefit received.
Conflict of Interest Laws are mentioned as well. Government Code §§ 87100-87103 prohibit public officials from participating in governmental decisions that could financially benefit their outside economic interests. The statute requires officials to recuse themselves from such decisions or face potential felony charges. The complaint alleges both officials violated these provisions by participating in decisions affecting SchoolsFirst while holding undisclosed positions with the credit union.
Perhaps most seriously, the complaint alleges violations of Government Code § 1090, which makes it a felony for public officials to have a financial interest in contracts they influence in their official capacity. Section 1090 violations can result in,
Felony charges punishable by up to three years in prison, forfeiture of office, permanent disqualification from holding public office, contract voidance, and civil penalties.
The financial entanglements allegedly extend beyond the hidden governance roles such as campaign contributions. SchoolsFirst’s political action committee contributed at least $6,000 to Alejandre’s campaign, money that was processed by DeNava in his role as campaign treasurer, even while DeNava served on SchoolsFirst’s board of directors. The complaint details a pattern of gifts from SchoolsFirst to SBCSS programs: Teacher of the Year awards ($250 checks to winners), backpack donations to schools, Various other gifts and sponsorships. These gifts allegedly don’t appear on required disclosure forms, raising questions about additional unreported benefits.
Beyond individual ethics violations, the complaint highlights a broader transparency failure. The SchoolsFirst contract appears nowhere in SBCSS’s adopted budgets for 2024-25 or 2025-26, nor in county board agendas, despite district policies requiring board approval for contracts exceeding $25,000. “There does not appear to have been a bidding or request for proposal “RFP process,” the complaint notes, “and the decision to contract with SchoolsFirst was done by Alejandre and DeNava” without public oversight.
These allegations strike at the heart of public trust in educational governance. San Bernardino County serves over 400,000 students across 33 school districts, with SBCSS overseeing billions in public funds and educational resources. The complaint paints a picture of systematic concealment, where the county’s top education officials allegedly maintained hidden financial relationships with a vendor while making decisions that could benefit that vendor, all while the public and their elected board remained unaware of these conflicts.
The FPPC now faces the task of investigating these allegations, which could result in: administrative penalties and fines, referral for criminal prosecution at both state and federal levels, requirement for officials to recuse themselves from related decisions, contract modifications or cancellations, and broader reforms to prevent future conflicts.
Federal Interest: Given the serious federal criminal exposure, this case could attract attention from the FBI’s Public Corruption Unit and the U.S. Attorney’s Office for the Central District of California. Federal prosecutors have successfully pursued similar cases involving educational officials who concealed conflicts of interest while steering contracts to favored vendors. For Alejandre and DeNava, the stakes are enormous. Beyond potential state criminal liability, federal charges could result in decades in prison, substantial financial penalties, and permanent federal consequences that would affect everything from future employment to federal benefits.
This alleged case reflects broader concerns about transparency and accountability in California’s complex educational governance structure, where county offices of education wield significant authority over public funds while often operating with less public scrutiny than local school districts.
As the FPPC investigation proceeds, the San Bernardino County education community will be watching closely to see whether California’s ethics laws have teeth when it comes to holding powerful education officials accountable for their conduct.
The complaint, filed by Antoinette Jensen, represents the type of citizen oversight that ethics laws are designed to encourage. Whether it leads to meaningful accountability remains to be seen.